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Proposed Treasury Regulations Clarify UBTI “Silo” Rule

Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed...more

5/19/2020  /  CARES Act , IRS , Tax Cuts and Jobs Act

Finally! Final Regulations Published for Section 965 Transition Tax

At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more

What Can Be Expected in Structured Finance and Securitization for 2018?

A continuation of the market trends from last year can be expected in 2018. Structured finance and securitization markets had a period of relative calm in 2017 as new regulations were incorporated into transactions. While no...more

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